Articles Posted in Iowa Supreme Court

by
The Supreme Court affirmed the judgment of the district court concluding that challenged portions of Iowa Administrative Code rule 441-78.1(4) violate the Iowa Civil Rights Act (ICRA) and determining that the Iowa Department of Human Services’ (DHS) denial of Medicaid coverage for gender-affirming surgeries was reversible, holding that the rule violates the ICRA’s prohibition against gender-identity discrimination. At issue was the language of rule 441-78.1(4) pertaining to the exclusion of Iowa Medicaid coverage of surgical procedures related to “gender identity disorders” violated the ICRA or the Iowa Constitution’s equal protection clause. The district court concluded that the challenged portions of the rule violated both the ICRA and the Constitution and that the DHS’s denial of Medicaid coverage for gender-affirming surgeries would result in a disproportionate negative impact on private rights and that the decision was unreasonable, arbitrary, and capricious. The Supreme Court affirmed, holding (1) rule 441-78.1(4)’s exclusion of Medicaid coverage for gender-affirming surgery violates the ICRA as amended by the legislature in 2007; and (2) under the doctrine of constitutional avoidance the Court did not address the constitutional claim. View "Good v. Iowa Department of Human Services" on Justia Law

by
The Supreme Court affirmed the decision of the court of appeals reversing the decision of the district court annulling a writ of certiorari challenging the decision of the City of Ames’s Zoning Board of Adjustment (ZBA) denying Ames 2304, LLC’s permit for an interior model of a nonconforming use residential structure, holding that the ZBA erred in denying Ames 2304’s interior remodeling permit because the remodel would not increase the number of dwelling units in the structure. The proposed remodel in this case would increase the number of bedrooms while maintaining the same number of apartment dwelling units. The ZBA determined that the local zoning ordinance prohibited this increase in the number of bedrooms because it would increase the intensity of the nonconforming use. The Supreme Court held that the ZBA erred in denying the interior remodeling permit because the zoning ordinance defined an “increase in intensity” as an increase in the number of dwelling units, and the remodel would not increase the number of dwelling units in the structure. View "Ames 2304, LLC v. City of Ames, Zoning Board of Adjustment" on Justia Law

by
The Supreme Court affirmed in part and reversed and remanded in part the judgment of the district court in this challenge to the decision of the Iowa Department of Human Services (DHS) denying a dentist’s requests for a state fair hearing, holding, among other things, that the district court erred in finding that Iowa Code 249A.4(11) requires DHS to afford the dentist a state fair hearing but correctly found that the administrative rules require DHS to give the dentist a state fair hearing. After a managed care organization (MCO) denied reimbursement of claims submitted by Plaintiff, a dentist who contracted with the MCO as a provider, Plaintiff sought review. DHS concluded that the issue of the MCO’s denials of reimbursement was not appealable to DHS. The district court concluded that Plaintiff was entitled to a state fair hearing and that Plaintiff could seek reimbursement from his indigent patients for claims not covered or reimbursed by the MCO. The Supreme Court remanded the case, holding (1) Plaintiff was entitled to a state fair hearing; (2) Plaintiff may bill patents for services not covered or reimbursed by the MCO, but only to the extent as set forth in this opinion; and (3) the district court erred in awarding Plaintiff attorney fees. View "Colwell v. Iowa Department of Human Services" on Justia Law

by
The Supreme Court reversed the judgment of the district court affirming the decision of the workers’ compensation commissioner declining to award benefits to a fast-food employee who suffered serious head injuries when he fell backwards directly to a tile floor after having a seizure while handling a customer order, holding that there is no blanket rule rendering certain categories of workplace idiopathic falls noncompensable. The commissioner reasoned that idiopathic falls from a standing or walking position to a level floor do not arise out of employment under the workers’ compensation law. The district court affirmed. The Supreme Court reversed, holding (1) whether injuries suffered in an idiopathic fall directly to the floor at a workplace arises out of employment is a factual matter, not a legal one, and the factual question to be determined is whether a condition employment increased the risk of injury; and (2) the commissioner in this case incorrectly treated a factual issue as a legal matter. View "Bluml v. Dee Jay's Inc." on Justia Law

by
The Supreme Court affirmed the judgment of the district court affirming the decision of the Iowa Department of Inspections and Appeals denying the petition filed by a manufacturer and seller of electronic game devices (Petitioner) seeking a declaration that its games were not subject to the registration provisions contained in Iowa Code 99B.53, holding that the Department’s actions were not unreasonable, arbitrary, capricious, or an abuse of discretion. In denying the petition, the Department concluded that the outcomes of the games were not primarily determined by the skill or knowledge of the operator, and therefore, the games were subject to registration. The district court affirmed. The Supreme Court affirmed, holding that the Department (1) properly interpreted the relevant statutes; (2) did not prejudice the substantial rights of Petitioner based upon an irrational, illogical, or wholly unjustifiable application of law to fact; and (3) did not prejudice the substantial rights of Petitioner unreasonably, arbitrarily, capriciously, or through an abuse of discretion. View "Banilla Games, Inc. v. Iowa Department of Inspections & Appeals" on Justia Law

by
The Supreme Court reversed the judgment of the district court in favor of the Board of Adjustment in this action brought of developers seeking the right to build apartments on adjoining properties they owned in Iowa City and remanded with directions to enter judgment in favor of the developers. After the City denied the developers’ plans, the developers brought actions against the City and its Board of Adjustment. The district court ruled against the developers, thus rejecting the developers’ argument that a 1987 court order allowed them to proceed. The Supreme Court reversed the district court’s ruling in favor of the Board, holding (1) the Board should have permitted the developers to proceed in accordance with the 1987 decree, and the developers were entitled to enforce the decree as “successors and assigns”; (2) the statute of limitations did not bar enforcement of the decree; and (3) the Board’s argument that the decree had expired by its terms because “a use [had] been developed or established” on the properties failed. View "TSB Holdings, LLC v. City of Iowa City, Iowa" on Justia Law

by
The thirty-day period set forth in Iowa Code 414.15, which requires a petition for writ of certiorari seeking review of a decision of a city zoning board of adjustment to be filed in district court “within thirty days after the filing of the decision in the office of the board,” is triggered when the board posts the decision on its public website, and what is posted must be an actual decision. Plaintiffs filed a petition for certiorari challenging two of the Board of Adjustment’s decisions. The City filed a motion to dismiss, asserting that the petition was untimely because it was not filed within thirty days of the challenged decisions. The district court granted the City’s motion. The Supreme Court reversed the district court’s order to the extent it dismissed the challenge brought by Plaintiffs to the Board’s refusal to revoke a special use permit but affirmed the order to the extent it dismissed their challenge to the Board’s initial recognition of that special use permit, holding that the challenge to the refusal to revoke the permit was timely because the unapproved minutes of a meeting posted to the Board’s website did not amount to “the filing of the decision.” View "Burroughs v. City Of Davenport Zoning Board Of Adjustment" on Justia Law

by
The Iowa Department of Transportation (IDOT) did not have the statutory authority from the legislature to promulgate administrative rules regulating automated traffic enforcement (ATE) systems located along primary roads. The enforcement of the IDOT’s rules resulted in three cities being ordered to relocate or remove several of their ATE cameras. The district court upheld both the IDOT’s rules and its decisions based on those rules. The Supreme Court reversed, holding that the rules were invalid and could not be enforced against the cities because the IDOT’s specific grants of authority did not support the rules. View "City of Des Moines v. Iowa Department of Transportation" on Justia Law

by
The court of appeals erred in ruling that a taxpayer avoided in Iowa inheritance tax through a private postmortem family settlement agreement (FSA). Here, the decedent, before his death, signed a beneficiary form listing the taxpayer as a contingent beneficiary of his brokerage account. That account transferred to the taxpayer upon the decedent's death. The Iowa Department of Revenue (IDOR) determined that the estate owed the inheritance tax on the full account value. The decedent’s grandchildren sued the taxpayer claiming that they were entitled to the brokerage account under the decedent’s will because the decedent lacked the mental capacity to execute an enforceable beneficiary designation for the account. The taxpayer settled the suit by transferring half the account value to the plaintiffs under an FSA. The taxpayer then sought a refund of part of the inheritance tax already paid. The IDOR denied a refund, determining that the taxpayer failed to establish incapacity. The district court affirmed. The court of appeals reversed, concluding that the FSA controlled the tax issue. The Supreme Court vacated the decision of the court of appeals and affirmed the district court judgment, holding that, without an adjudication of incapacity, the FSA was not binding on the IDOR and could not avoid the inheritance tax. View "Nance v. Iowa Department of Revenue" on Justia Law

by
The court of appeals erred in ruling that a taxpayer avoided in Iowa inheritance tax through a private postmortem family settlement agreement (FSA). Here, the decedent, before his death, signed a beneficiary form listing the taxpayer as a contingent beneficiary of his brokerage account. That account transferred to the taxpayer upon the decedent's death. The Iowa Department of Revenue (IDOR) determined that the estate owed the inheritance tax on the full account value. The decedent’s grandchildren sued the taxpayer claiming that they were entitled to the brokerage account under the decedent’s will because the decedent lacked the mental capacity to execute an enforceable beneficiary designation for the account. The taxpayer settled the suit by transferring half the account value to the plaintiffs under an FSA. The taxpayer then sought a refund of part of the inheritance tax already paid. The IDOR denied a refund, determining that the taxpayer failed to establish incapacity. The district court affirmed. The court of appeals reversed, concluding that the FSA controlled the tax issue. The Supreme Court vacated the decision of the court of appeals and affirmed the district court judgment, holding that, without an adjudication of incapacity, the FSA was not binding on the IDOR and could not avoid the inheritance tax. View "Nance v. Iowa Department of Revenue" on Justia Law